PRIVACY POLICY

Effective Date: Jan 2025

Institutional 1031, Inc. (“Institutional 1031,” “we,” “our,” or “us”) respects your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you visit www.institutional1031.com, communicate with us, or use our Qualified Intermediary and related 1031 exchange services (collectively, the “Services”).

1. Information We Collect

We collect information in the following ways:

a. Information You Provide

When you contact us, submit forms, or begin an exchange, we may collect:
  • Name, phone number, email address, and mailing address
  • Property and transaction information related to your exchange
  • Bank, escrow, and wire details necessary to process funds
  • Professional affiliations (attorney, CPA, advisor, broker-dealer, etc.)
  • Communications or documents you voluntarily upload or send to us

    • b. Information We Collect Automatically

    When you visit our website, we may automatically collect:

  • IP address and device identifiers
  • Browser type, operating system, and referring URLs
  • Pages viewed, time spent, and interactions with our site
  • Cookies and similar tracking technologies for functionality and analytics
    • c. Information from Third Parties

    We may receive information from service providers, referral partners, custodial banks, or identity-verification vendors when necessary to fulfill an exchange or comply with legal requirements.

    2. How We Use Your Information

    We use your information to:

  • Verify identity and eligibility for 1031 exchange services
  • Prepare and execute Qualified Intermediary agreements and related documents
  • Facilitate secure transfers of exchange funds
  • Communicate with you, your representatives, and authorized parties
  • Maintain accurate records for compliance and reporting
  • Improve our website, services, and user experience
  • Meet legal, regulatory, and security obligations
  • We do not sell or rent your personal information to anyone.

    3. How We Share Information

    We may share your information with:

  • Custodial Banks or Escrow Agents – to hold and release exchange funds under IRS guidelines.
  • Technology & Security Providers – for portal hosting, encryption, email, and identity verification.
  • Professional Advisors or Counterparties – only when authorized by you or required for your transaction.
  • Legal, Regulatory, or Law Enforcement Entities – when required by law or to protect our rights.
  • All third-party vendors are contractually bound to maintain confidentiality and data protection standards consistent with this policy.

    • 4. Data Security

    We implement administrative, technical, and physical safeguards to protect your information.

    These include:

  • AES-256 encryption for data at rest and TLS 1.2+ encryption in transit
  • Role-based access controls and least-privilege permissions
  • Segregated exchange accounts and multi-party authorization for fund movement
  • Secure document storage and deletion protocols
  • While we take reasonable precautions, no electronic system is completely secure. You acknowledge and accept this risk when transmitting data to us.

    • 5. Data Retention

    We retain information for as long as necessary to:

  • Complete your exchange and meet legal retention requirements
  • Comply with IRS, banking, and anti–money laundering regulations
  • Resolve disputes and maintain business records
  • After retention periods expire, data is securely deleted or anonymized.

    • 6. Your Rights and Choices

    Depending on your state or country of residence, you may have rights to:

  • Access or request a copy of the personal information we hold about you
  • Request correction or deletion of your personal information
  • Opt out of certain communications or data sharing (except where legally required)
  • To exercise these rights, contact us at [email protected].
  • We may need to verify your identity before processing your request.

    • 7. Cookies and Tracking

    We use cookies and similar technologies to:

  • Improve site performance and user experience
  • Measure site traffic and engagement (Google Analytics, etc.)
  • Remember preferences and form data
  • You can control cookies through your browser settings. Some functions may not operate properly if cookies are disabled.

    • 8. Links to Other Websites

  • Our website may contain links to third-party sites (e.g., partner platforms or custodians).
  • We are not responsible for the privacy practices or content of those sites. Please review their policies before providing personal information.

    • 9. Children’s Privacy

  • Our Services are intended for adults engaged in legitimate investment or real estate transactions.
  • We do not knowingly collect information from children under 18 years of age.

    • 10. Changes to This Policy

  • We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations.
  • The “Effective Date” at the top will indicate the latest revision.
  • We encourage you to review this page regularly.

    • 11. Contact Us

    If you have questions or concerns about this Privacy Policy or our data practices, please contact:

    Institutional 1031, Inc.

    Email: [email protected]

    Phone: 866 550 1031